If I’m reading you right, you’re talking about something like Epic’s “sticky note” system, where providers can leave general comments about a patient not associated with specific encounter? That’s a really good question - and one I’d have to leave up to an attorney. My naive guess would be that the patient’s right to access those may depend on whether or not a practice is using them to store health information, or just general non-medical tidbits (I believe some orgs tell staff not to keep any PHI in them as a matter of policy).